NATHANIEL BROWN
v.
STATE OF FLORIDA
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A trial court does not abuse its discretion in denying a motion for mistrial unless an error is so prejudicial as to vitiate the entire trial, not merely because evidence is prejudicial.
[1] A ruling on a motion for mistrial is reviewed for an abuse of discretion.
[2] A trial court does not abuse its discretion by denying a motion for mistrial merely because evidence is prejudicial; rather, a mistrial is warranted only when an error is…
Previewing 2 of 3 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“The trial court should not grant a motion for mistrial merely because an error is prejudicial. Rather, the lower court should grant a mistrial only when 'an error is so prejudicial as to vitiate the entire trial.'”
Standard applied to review trial court's denial of motion for mistrial.
Nathaniel Brown appealed a decision from the Circuit Court for Miami-Dade County, challenging the trial court's denial of his motion for mistrial. The…
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Third District Court of Appeal State of Florida
Opinion filed March 31, 2026. Not final until disposition of timely filed motion for rehearing.
No. 3D25-0399 Lower Tribunal No. F22-23158
Nathaniel Brown, Appellant,
vs.
State of Florida, Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Andrea R. Wolfson, Judge.
Carlos J. Martinez, Public Defender, and Jennifer Thornton, Assistant Public Defender, for appellant.
James Uthmeier, Attorney General, and Ivy R. Ginsberg, Assistant Attorney General, for appellee.
Before SCALES, C.J., and EMAS and MILLER, JJ.
PER CURIAM.
Affirmed. See Guzman v. State, 214 So. 3d 625, 632 (Fla. 2017) (holding that a ruling on a motion for mistrial is reviewed for an abuse of discretion); Ward v. State, 306 So. 3d 1004, 1007 (Fla. 3d DCA 2020) (“The trial court should not grant a motion for mistrial merely because an error is prejudicial. Rather, the lower court should grant a mistrial only when 'an error is so prejudicial as to vitiate the entire trial[.]” (citation omitted) (quoting Jennings v. State, 124 So. 3d 257, 265 (Fla. 3d DCA 2013))); Granados v. State, 199 So. 3d 384, 389 (Fla. 4th DCA 2016) (holding that, once a defendant takes the stand and his credibility becomes an issue at trial, the State can expose contradictions and improbabilities in his testimony).
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Jennings v. State, 124 So. 3d 257 (Fla. 3d DCA 2013)
- Guzman v. State, 214 So. 3d 625 (Fla. 2017)
- Granados v. State, 199 So. 3d 384 (Fla. 4th DCA 2016)